SCHIFFSTECHNIK | SHIP
SCHIFFSTECHNIK | SHIP TECHNOLOGY 38 HANSA – International Maritime Journal 03 | 2021
SCHIFFSTECHNIK | SHIP TECHNOLOGY »This is a minefield« Ballast water management regulations and testing are still causing confusion, as Michael Haraldsson, General Manager Ballast Water at CTI Maritec, explains © CTI Maritec Haraldsson is active in the ballast water market since 2008. Now he is working for CTI Maritec, the Singaporebased maritime division of the Chinese CTI Group, an independent testing lab specialising in testing for ballast water, fuels, water, hazardous materials, asbestos etc. As he explains, a problem in the field of the ballast water management arises from the differences in IMO and US Coast Guard requirements. The regulation of the US Environmental Protection Agency (EPA) differentiates between »live« and »dead« organisms, the IMO differentiates »viable« and »nonviable«. While the IMO requires a system to only sterilize organisms, the Americans want them dead. The problem is known today and the system makers – mainly UV systems were concerned – have reacted by allowing higher power settings. But back in 2012, when Haraldsson got hold of the draft statement for the US’ Vessel General Permit (VGP), he was alarmed and tried to make the market aware of it. But still today there is a lot of insecurity, uncertainty and lack of knowledge in the market, he claims, especially when it comes to testing versus type-approval. A type-approved system works in principle, but the installation is a different story. Haraldsson is a strong advocate for commission-testing, where the installation and not the system is tested. Having a type-approved system inszalled does not mean, that a ship automatically meets the regulation. It also has to work properly. »This is a minefield,« he says. The IMO MEPC 75 in 2020 had addressed the issue and revised its guidance on sampling and analysis. The new version of the IMO regulation will come into force in June 2022. So far, commission-testing after installation is not mandatory – except for a few flag states that require it: Australia, Singapore, Cyprus, Greece and Tuvalu. »CTI needed someone to know the regulations and who knows how to read them. Just in the few months that I have been here, I realized that big shipowners and big shipyards have no idea what they are doing. For managers and owners there are so many regulations – I understand that. But this is something we have to talk about,« he says. »An indicative test cannot read if organisms have been sterilized or not. If it is moving, it is alive« Indicative testing can be enough in certain cases while in others detailed lab testing is the only way to go, as the expert explains. »The biggest problem we see here is that if you have a UV system that runs in IMO mode (viable/non viable organisms) and conduct indicative testing, the instrument you use on a ship can only read living organisms. It cannot read if they have been sterilized or not. If it is moving, it is alive,« Haraldsson says. This means Michael Haraldsson that a system running in IMO mode would require detailed testing right away. An active substance system just kills everything should be o.k. with indicative testing. The same applies to a UV system that runs in the higher power VGP mode For indicative testing only a mall tube of water is taken from the ballast water tank or from the discharge. »You put it into a machine and it tells you what’s up. In detailed testing we take it to a lab, put it under the microscope and count the organisms. If you test for sterile or nonsterile organisms, you have to see how many grow over a certain time period. This can take a couple of weeks,« Haraldsson explains. HANSA – International Maritime Journal 03 | 2021 39
